NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam3745OpenMr. Otto Major, 219 West Bel Air Avenue, Aberdeen, MD 21001; Mr. Otto Major 219 West Bel Air Avenue Aberdeen MD 21001; Dear Mr. Major: This is in response to your letter of August 18, 1983, in which yo assert that the Maryland Certificate of Title does not comply with the Federal Odometer disclosure statement requirements.; Your assertion is incorrect. States are permitted to use their titl documents in lieu of a separate Federal form, provided that the State form contains the odometer disclosure information specified in 49 CFR Part 580. Maryland's Certificate of Title contains this information and, therefore, satisfies the Federal odometer disclosure statement requirements. For your information, I have enclosed a copy of Part 580.; You also requested an interpretation regarding whether the installatio of a replacement engine of unknown mileage will require the transferor to report the mileage on the certificate as being unknown. The answer is no.; Section 408 of the Motor Vehicle Information and Cost Savings Act, 1 U.S.C. S 1968, and its implementing regulations, require the transferor of a motor vehicle to disclose to the transferee the cumulative mileage registered on the odometer or, that the actual mileage is unknown, if the odometer reading is known to be different from the number of miles the *vehicle* has actually traveled.; The Act does not require the separate disclosure of the number of mile traveled by the motor vehicle components, nor is there a mechanism in motor vehicles to measure the distance traveled by each component. Therefore, the installation of a replacement engine will not change the disclosure requirements of the transferor.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3250OpenSteven J. Kalies, Ed.D, Asst. Supt. for Business, Union Springs Central School District, Union Springs, NY 13160; Steven J. Kalies Ed.D Asst. Supt. for Business Union Springs Central School District Union Springs NY 13160; Dear Dr. Kalies: This is in response to your letter of January 22, 1980, asking whethe the Dubl-Life Saver Support restraint vest manufactured by Easy Way Products Co. is in compliance with applicable Federal motor vehicle safety standards. The advertisement you enclosed with your letter describes the Dubl-Life Saver as a support restraint vest for the safe transportation of all sizes of handicapped children in motor vehicles. The advertisement further claims that the safety belts used with the vest exceed 'federal specifications'.; Based on the information in the advertisement, it appears that th restraint vest does not provide pelvic restraint and thus does not comply with Standard No. 209, *Seat Belt Assemblies*. I have referred this matter to the agency's Office of Vehicle Safety Compliance for appropriate action.; The University of Michigan's Highway Safety Research Institute ha conducted tests of various devices used to restrain handicapped children. I have enclosed a copy of a Society of Automotive Engineers paper describing the results of the testing.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4595OpenMr. James R. Tomaino Youngstown Rubber Products Company 854 Mahoning Avenue P.O. Box 1377 Youngstown, OH 44501-1377; Mr. James R. Tomaino Youngstown Rubber Products Company 854 Mahoning Avenue P.O. Box 1377 Youngstown OH 44501-1377; "Dear Mr. Tomaino: This responds to your January 30, 1989 letter askin whether a 'permanently embossed raised dot' on your air brake hose assembly satisfies the requirement in Standard No. 106, Brake Hoses, for a manufacturer identification. As explained below, we believe that use of the raised dot may be potentially confusing, since it isn't readily apparent whether the mark represents an intentional effort to identify the manufacturer of the assembly or is an accidental by-product of the manufacturing process. By way of background, Standard No. 106 sets forth two methods of labeling air brake hose assemblies made with crimped or swaged end fittings. S7.2.3 states that these assemblies must be labeled by means of a band around the assembly or, at the option of the assembly manufacturer, by means of marking at least one end fitting as described in S7.2.3.1. You have asked us about the labeling requirements under the second option. Since, for reasons of drafting convenience, the second option incorporates the portions of the first option relating to the nature of and filing of the designation, it is necessary to begin with a discussion of the first option. The first option (S7.2.3(b)) provides that the band must be marked with information including: A designation that identifies the manufacturer of the hose assembly, which shall be filed in writing with: Office of Vehicle Safety Standards, Crash Avoidance Division, National Highway Traffic Safety Administration, 400 Seventh St., SW, Washington, D.C. 20590. The designation may consist of block capital letters, numerals or a symbol. (Emphasis added.) The second option (S7.2.3.1) requires assemblies to be 'etched, stamped or embossed with a designation at least one-sixteenth of an inch high that identifies the manufacturer of the hose assembly and is filed in accordance with S7.2.3(b).' (Emphasis added.) The concluding language, 'in accordance with S7.2.3(b),' modifies both of the preceding clauses, i.e., both 'identifies the manufacturer of the hose assembly' and 'is filed.' Thus, the identification provided in compliance with the second option 'may consist of block capital letters, numerals or a symbol.' Since the raised dot is clearly neither a block capital letter or a numeral, the issue is whether it can be considered a symbol. The dictionary defines 'symbol,' for the purposes relevant to your inquiry, as follows: 'something that stands for or suggests something else by reason of relationship, association, convention, or accidental but not intentional resemblance.' (Webster's Third New International Dictionary, unabridged edition.) The agency concludes that the dot is not a symbol because it is not readily apparent that the raised dot stands for or suggests anything. Instead, the dot appears to be only an accidental by-product of the manufacturing process. Manufacturer identification is crucial for the enforcement of Standard No. 106's requirements and the tracing of defective assemblies. We urge you to use a more distinctive mark to identify your company as the manufacturer of the assembly. To assist you, and in response to your March 17 telephone request, we are enclosing examples of designations which manufacturers of brake hoses, fittings and assemblies have registered with NHTSA. These examples should be helpful in providing ideas for another designation. Please let me know if we can be of further assistance. Sincerely, Erika Z. Jones Chief Counsel Attachment"; |
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ID: aiam0885OpenMr. Ray Brown, Pine Ridge Nursery, 14484 Cedar Avenue, Rosemount, MN 55068; Mr. Ray Brown Pine Ridge Nursery 14484 Cedar Avenue Rosemount MN 55068; Dear Mr. Brown: Thank you for your letter of October 11, 1972, regarding th installation of LP gas tanks in a small van to serve as a 'recreational vehicle.'; There is no Federal regulation regarding installation of LP gas tank on the exterior of recreational vehicles.; There is a voluntary standard on recreational vehicles issued by th National Fire Protection Association (NFPA), 60 Batterymarch Street, Boston, Massachusetts 02110, identified as NFPA Standard No. 501C. This standard includes requirements for fuel supply systems based on the use of LP gas. You may wish to refer to the standard for safety guidance in installing your system.; I appreciate you interest in motor vehicle safety.Sincerely, Robert L Carter, Associate Administrator, Motor Vehicle Programs; |
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ID: aiam1797OpenMr. J. T. Blewett, Great Dane Trailers, Inc., Lathrop Avenue, P.O. Box 67, Savannah, GA 31402; Mr. J. T. Blewett Great Dane Trailers Inc. Lathrop Avenue P.O. Box 67 Savannah GA 31402; Dear Mr. Blewett: This responds to your January 8, 1975, request for confirmation tha air-braked trailers built after January 1, 1975, for export to Mexico (and therefore without brake systems conforming to Standard No. 121, *Air brake systems*) may re-enter the United States on a continuing basis on railway cars for marshalling and unloading. Your letter states that the trailers would not be used in interstate commerce, by which we understand they would not operate on public streets or highways.; The NHTSA would not consider this limited introduction of non-complyin trailers into the United States an importation or introduction into interstate commerce for purposes of S108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1397). This means that the trailer could legally be brought into the United States on a railway car to be unloaded on private property and returned by railway car to Mexico. These vehicles could not be operated on the public highway without violating S 108(a)(1)(A). I enclose a copy of a letter on this subject for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2912OpenMr. R.W. Fink, AMF Incorporated, 3700 W. Juneau Avenue, P.O. Box 653, Milwaukee, Wisconsin 53201; Mr. R.W. Fink AMF Incorporated 3700 W. Juneau Avenue P.O. Box 653 Milwaukee Wisconsin 53201; Dear Mr. Fink: This is in reply to your letter of November 7, 1978, concerning th lettering permissible under Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your conversation with Mr. Schwartz of my office.; Paragraph S4.3.1 of the standard provides that the type face utilize for the vehicle identification number shall consist of capital, san serif characters. Although the '1' in the 'posident' type face which you propose to use has a slight serif at the top, the type face would still be considered sans serif. Consequently, there is no bar to utilizing 'posident' if you desire.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3600OpenThe Honorable John Glenn, United States Senator, 200 North High Street, Suite 600, Columbus, OH 43215; The Honorable John Glenn United States Senator 200 North High Street Suite 600 Columbus OH 43215; Dear Senator Glenn: This responds to your July 1, 1982, letter enclosing correspondenc from your constituent Mr. Donald M. Robinson. Mr. Robinson would like to know whether Federal regulations prohibit him from purchasing a pickup cab and chassis without the body attached. The answer to his question is no.; The National Highway Traffic Safety Administration only requires tha all vehicles be manufactured in compliance with the applicable motor vehicle safety standards. We have no requirement, nor do we know of any other Federal regulation, that would prevent Mr. Robinson from purchasing just the cab and chassis of a vehicle that he desires. When he adds his own utility body to the cab and chassis, he would become the final-stage vehicle manufacturer and would be required to certify that the completed vehicle complies with all applicable Federal safety standards. I am enclosing copies of the regulations pertinent to such an operation.*; If I can be of further assistance to you or Mr. Robinson, pleas contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5384OpenMr. Robin Liu President Introbusy 1320 Girard Street San Francisco, CA 94134; Mr. Robin Liu President Introbusy 1320 Girard Street San Francisco CA 94134; "Dear Mr. Liu: This responds to your letter of April 18, 1994, wit respect to a supplementary stop lamp that you intend to import into the United States. You have asked whether you 'need to get any official approval or to apply any license to ensure that installing this product in motor vehicle will not violate the regulation of Transportation Department.' There are no requirements of the Department of Transportation (DOT) that a supplementary stop lamp must meet. You do not have to receive DOT approval, or apply for a license. The authority of this agency over installation of supplementary lighting equipment differs, according to whether the equipment is 'original' (installed by the vehicle dealer or manufacturer before the vehicle's first sale) or 'aftermarket' (installed after the vehicle's first sale). We believe that you intend your lamp for sale in the aftermarket. If your lamp is installed by the owner of the vehicle itself, there are no Federal laws that must be considered. However, it is subject to the laws of the States in which the lamp is operated. We are unable to advise you on these laws and suggest that you write for an interpretation to: American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. However, if your lamp is installed by someone other than a vehicle owner, specifically by a manufacturer, distributor, dealer or motor vehicle repair business, under Federal law (l5 U.S.C. 1397(a)(2)(A)) the question must be asked whether your lamp will 'render inoperative in whole or in part' the center stop lamp or other stop lamps which have been installed in accordance with a Federal regulation (49 CFR 571.108 Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment. Literally, these lamps will continue to operate, however, if their signal is not clearly perceived as stop signals, then, in our view, they have been rendered partially inoperative within the meaning of the statutory prohibition. The supplementary stop lamp depicted in the photos you enclosed is mounted atop a vehicle's center highmounted stop lamp. It connects '+/- wire to manufacturer's braking light system.' The one shown is in the shape of a snowman, but others are available as Santa Claus, pumpkins, sports figures, etc. The photo of your snowman stop lamp in operation indicates that an interior bulb shines through the exterior and, in this case, gives a distinctly white light in contrast to the red of the center lamp on top of which it is mounted. Thus, we believe that when the snowman lamp operates simultaneously with the other stop lamps there could be momentary confusion on the part of a following driver, in other words, that the stop lamps will be rendered partially inoperative. If your lamp is installed before the first sale of a vehicle (for example, by the vehicle dealer), under Standard No. 108 (S5.1.3) the question must be asked whether your lamp would impair the effectiveness of the center and other stop lamps. Because of the possibility of momentary confusion discussed above, we believe that your lamp could impair the effectiveness of the stop lamps which are required under Standard No. 108. There is also the possibility that installation of the lamp could affect compliance of the vehicle with the interior field of view requirements (S5.1.1) of Motor Vehicle Safety Standard No. 111 Rearview Mirrors. In summary, while there is no restriction upon your importation and sale of this device, we believe that its installation would raise problems of compliance with Federal laws. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2441OpenMr. James A. Rupp, Vice President and General Manager, Kustom Fit of Ohio, Inc., P.O. Box 216, Pioneer, OH 43554; Mr. James A. Rupp Vice President and General Manager Kustom Fit of Ohio Inc. P.O. Box 216 Pioneer OH 43554; Dear Mr. Rupp: This responds to your April 30, 1976 request for confirmation tha 'liability' for the correct location of a vehicle's seating reference point (SRP) lies with a vehicle manufacturer or alterer that installs seating and not with the manufacturer of the seat. I regret that we have not responded to your request sooner.; >>>'Seating reference point' is defined by NHTSA regulations (49 CFR 571.3) to mean --; . . . .the manufacturer's design reference point which -- (a) Establishes the rearmost normal design driving or riding positio of each designated seating position in a vehicle,; (b) Has coordinates established relative to the designed vehicl structure,; (c) Simulates the position of the pivot center of the human torso an thigh, and; (d) Is the reference point employed to position the two dimensiona templates described in SAE recommended Practice J826, 'Manikins for Use in Defining Vehicle Seating Accommodation', November 1962.<<<; While the term 'manufacturer' found in the beginning of this definitio could refer to either a vehicle or equipment manufacturer under the relevant statutory definition (15 U.S.C. & (sic) 102(5)), the references in subparagraphs (a) and (b) make clear that the SRP is a location established with reference to the vehicle structure. It is a commonly understood reference point for specifying the available space for a seated occupant within a vehicle. The only exception to this relationship to the vehicle has been in the case of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, where the NHTSA has indicated it would accept an SRP designation that is established with reference to the seat frame. This policy is limited to school buses where seat placement within the vehicle is subject to more variation than in other vehicle types.; This means that the NHTSA, in verifying the compliance of a vehicl with a standard such as Standard No. 210, *Seat Belt Anchorages*, will ask the vehicle manufacturer for the location of the SRP.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0186OpenMr. Heinz C. Hoppe, Executive Vice President, Mercedes-Benz of North America, Inc., 158 Linwood Plaza, Fort Lee, NJ 07024; Mr. Heinz C. Hoppe Executive Vice President Mercedes-Benz of North America Inc. 158 Linwood Plaza Fort Lee NJ 07024; >>>Re: Consumer Information<<< Dear Mr. Hoppe: We have received your submittal of consumer information in response t the requirements of 49 CFR Part 375. That regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to purchasers, the following comments are only advisory in nature. There is one respect, however, in which the information, if supplied in this form to prospective purchasers, would not satisfy the requirements of the regulations.; The Consumer Information section on Vehicle Stopping Distance, 49 CFR 375.101, specifies that the information presented shall contain 'the most adverse combination of maximum or lightly loaded vehicle weight and complete logs of braking in any one of the vehicle brake subsystems.' In your submittal, you have presented information for failures in each of the front and rear subsystems, instead of selecting the most adverse combination of weights and system failures. This is likely to confuse consumers attempting to compare vehicles of different manufacturers, and fails to satisfy the requirement that the information shall be submitted 'in essentially the form illustrated in Figure 1' of S 375.101.; We will be glad to answer any questions that you may have with respec to the requirements of these or other motor vehicle safety regulations and standards.; Sincerely, Robert Brenner, Acting Director |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.